Sign in Sign up
OFAC ·

OFAC requires U.S. persons to file 2026 Annual Report of Blocked Property by 30 September

U.S. persons holding OFAC-blocked property as of 30 June 2026 must file the Annual Report of Blocked Property via the OFAC Reporting System by 30 September 2026, or commit an RPPR violation

Financial Services Sanctions
Save
Change
The Office of Foreign Assets Control (OFAC) confirmed that 31 C.F.R. § 501.603 of the Reporting, Procedures and Penalties Regulations (RPPR) requires U.S. persons holding blocked property as of 30 June 2026 to file the 2026 Annual Report of Blocked Property (ARBP) using spreadsheet form TD-F 90-22.50 through the OFAC Reporting System by 30 September 2026; failure to file constitutes a violation of the RPPR.
Why it matters
Only property blocked pursuant to OFAC regulations as of 30 June 2026 is reportable; property unblocked by an OFAC general or specific license, or previously blocked under a sanctions program terminated on or before 30 June 2026, must be excluded, as must a restricted account of a person ordinarily resident in Iran unless a blocked person has an interest in it. Filers must use spreadsheet form TD-F 90-22.50 and submit it through the OFAC Reporting System (ORS) by the 30 September 2026 deadline; missing the deadline is a violation under the RPPR.
Implications
  • — U.S. persons holding OFAC-blocked property as of 30 June 2026 — including sanctions and compliance teams at banks, funds, insurers and other institutions — must compile and file the 2026 ARBP on spreadsheet form TD-F 90-22.50 via the OFAC Reporting System by 30 September 2026, because failure to file by the deadline constitutes a violation of 31 C.F.R. § 501.603.
  • — Filers must scope the report to property blocked pursuant to OFAC regulations as of 30 June 2026 only — excluding property unblocked by a general or specific license, property under a sanctions program terminated on or before 30 June 2026, and Iran-resident restricted accounts in which no blocked person has an interest — because mis-scoping the ARBP risks an inaccurate filing.
Who is affected
  • — U.S. persons holding OFAC-blocked property as of 30 June 2026
  • — Sanctions and compliance teams at banks, funds, insurers and other institutions holding blocked property
What to watch
  • — 30 September 2026 — 2026 ARBP submissions due; failure to file constitutes a violation of the RPPR.
View on OFAC
Clarify with AI

Grounded in this brief. 10 free questions left this month.

Clarify with AI — Pro only

You asked:

Clarify turns any brief into answers specific to your role and exposure.

Pro includes

Implications — what this change may force you to review
Who is affected — which people, workflows, or obligations are touched
What to watch — dates, deadlines, and triggers that matter next
Real-time alerts — delivered when a decision-forcing change is published
Clarify with AI — ask what this change means for you

$29/month · Founding rate, locked for life. Cancel anytime.

Create a free account to keep clarifying

You asked:

You've used your free guest questions for now. A free account gives you more every month and saves your history — or start a Pro trial for unlimited Clarify and real-time alerts.

Pro includes

Implications — what this change may force you to review
Who is affected — which people, workflows, or obligations are touched
What to watch — dates, deadlines, and triggers that matter next
Real-time alerts — delivered when a decision-forcing change is published
Clarify with AI — ask what this change means for you

Free account: no card, ever. Pro trial: $29/month after 14 days, no card to start, cancel anytime.

Create free account Start 14-day Pro trial Sign in

Awareness was never the problem. Translation is.

Your team doesn't miss the change — it loses hours turning a 60-page regulator notice into “what do we actually do.” OwlBrief delivers that as a sourced, decision-ready brief the moment a change publishes.

Get the next brief free →
Similar briefs